The tax strategy sets out Atlantia SpA’s objectives and approach in managing tax, both its own and that of Group companies. It derives from the Board of Directors’ wish to implement an internal tax control framework (the Tax Control Framework or “TCF”) that is fully compliant with international standards and agreed with the OECD and tax authorities in Italy and in the other main countries in which the Group operates.

The tax strategy is a component of the Tax Control Framework, which forms a part of Atlantia’s wider Internal Control and Risk Management System. The Tax Control Framework is based on the principles set out in the Code of Ethics and extends the oversight provided for in the organisational, management and control model adopted in compliance with Legislative Decree 231 of 8 June 2001, with the aim of preventing the commission of offences that could result in the Company’s administrative liability.

Atlantia shall follow the following strategic guidelines in managing tax and shall:

Icona Fair Share of taxes
Fair Share of taxes

Ensure prompt compliance with tax requirements and payment of the right amount, without necessarily choosing to pay the highest amount payable:

  • as a taxpayer, Atlantia has an obligation to the State and to the public to pay the tax due under the law;
  • as a business, Atlantia has an obligation to its shareholders and stakeholders not to pay more tax than is due under the law, ensuring in any event that it takes advantage of any legitimate tax savings and permitted tax benefits.
Icona Rischi fiscali
Tax risk
Control and manage tax risk: a commitment to manage and reduce the risk of violating tax laws or abusing the principles and purposes of tax legislation.
Icona Etica fiscale
Tax ethics
Develop awareness, within the Group’s organisation, of the value of honesty and integrity, which, in the Tax Strategy, form the basis of the approach to managing tax.
Icona Trust and Transparency
Trust and Transparency
Develop close relationships with the relevant tax authorities, operating transparently and correctly.
Icona Corretta applicazione della normativa fiscale
Correct application of tax legislation

Commit to applying the tax legislation of the countries in which it operates, ensuring compliance with the both the spirit and intent of the regulations or legislation as they apply to the matter under interpretation.

Should tax legislation give rise to interpretative doubts or difficulties in application, Atlantia shall adopt a reasonable interpretation, availing itself of the support of external experts and consulting the relevant tax authority.

Icona Agree to disagree
Agree to disagree
Protect the interests of the Group and its shareholders and, when in dispute or otherwise, support solid and reasonable interpretations, even when not agreed with the tax authority.
Icona Piena collaborazione con le autorità fiscali
Full cooperation with the tax authorities
Behave transparently and correctly in its dealings with tax authorities, encourage Group companies to engage in cooperative compliance over and above the requirements of domestic tax legislation and comply with the provisions regarding transfer pricing documentation.
Icona Tax Control Framework
Tax Control Framework
Implement a Tax Control Framework, as recommended by the OECD and agreed with the Italian tax authority. The largest Group companies shall progressively adopt a Tax Control Framework.
Icona Soft Controls
Soft Controls
  • A report on an assessment of the Tax Control Framework and of major tax risks shall be submitted to Atlantia’s Board of Directors annually.
  • Atlantia shall encourage dissemination of a tax compliance culture and awareness of the value of compliance.
  • Atlantia shall not enter into arrangements or transactions of an artificial nature, that do not reflect economic realities and that are reasonably expected to result in undue tax benefits.
  • Cross-border intra-group transactions shall be treated, for tax purposes, in accordance with the arm’s length principle, as defined by the OECD.
  • There must be no management incentive schemes linked to undue reductions in the tax burden."

The tax strategy has been approved by Atlantia’s Board of Directors. The objectives and principles shall also be adopted by the other Group companies via a specific resolution to be adopted by their boards of directors.

The tax strategy and any revisions shall come into force from the first day after the date of approval by Atlantia SpA’s Board of Directors and publication on the Company’s website at www.atlantia.it. The related interpretation shall also be passed on to Atlantia’s Tax Affairs department, which is responsible for its revision.